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STEP CRA Roundtable – June 13, 2017 QUESTION 2. GAAR and Capital Distribution to Canco Beneficiary At the 2016 CTF Annual Tax Conference Roundtable, the CRA indicated that it was considering whether the general anti-avoidance rule (“GAAR”) in subsection 245(2) should apply to a situation involving a distribution from a discretionary family trust to a Canco the shares of which are held by a newly established discretionary family trust, thereby avoiding the 21-year deemed disposition that would have otherwise applied if the property had not been distributed by the first trust. ...

STEP CRA Roundtable – June 13, 2017 Question 8. Articles IV and XXVI: Single-member disregarded U.S. ...

13 June 2017 STEP Roundtable Q. 3, 2017-0693451C6- Dual-resident estate and Article (IV) Principal Issues: Dual-resident estate and Article (IV) Position: Response provided by Competent Authority STEP CRA Roundtable – June 13, 2017 QUESTION 3. ...

Also, all the applicable conditions in section 118.2 of the Act must be met in order to claim amounts paid as medical expenses. 2017 CTF Annual Conference CRA Roundtable Question 16: Medical Expenses – Medical Assistance in Dying The Supreme Court recently issued its ruling in Carter v. ...

Reasons: The exception in subsection 112(3.32) should be applicable to exclude from the calculation in paragraph 112(3.2)(b) any qualified dividends that are ultimately paid in the year to a beneficiary that is an individual (other than a trust). 2018 STEP CRA Roundtable – May 29, 2018 QUESTION 15. ...

Reasons: Prior positions. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 12. ...

Position: Question of fact and will depend whether one of the reasons for Opco paying the dividends to the Holdcos can reasonably be considered to be to reduce the amount of the "adjusted aggregate investment income" of the associated group for the purposes of the "passive income reduction" rule in paragraph 125(5.1)(b). 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 16. ...

Reasons: See below. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 2. ...

Reasons: Individual is actively engaged in the activities of Opco's business based on the facts and circumstances and work performed. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 3. ...

Reasons: See comments. 2019 CTF Annual Conference CRA Roundtable Question 9: TOSI – Excluded Amount and the Non-Related Business Exception For individuals age eighteen or over, income which is not derived directly or indirectly from a related business in respect of the individual is an “excluded amount” (subparagraph (e)(i) of the definition of that term in subsection 120.4(1)). ...